Mel T. Nelson v. Commissioner

110 T.C. No. 12

UNITED STATES TAX COURT MEL T. NELSON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 20811-95. Filed February 19, 1998. Petitioner was the sole shareholder of M, an S corporation. In the 1991 taxable year, M was insolvent. In that year, M disposed of all of its assets and realized discharge of indebtedness income pursuant to sec. 61(a)(12), I.R.C. In accordance with sec. 108(a), I.R.C., M excluded from gross income the entire amount of the discharge of indebtedness income. Sec. 108(a), I.R.C., excludes from gross income, discharge of indebtedness income…